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r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t
ted States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en bane) 54 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 86 United States
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
pson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorvee, 616 F.3d 174, 180 (2d Cir. 2010) ("We do not believe that the district court was clearly erroneous in finding, as a matter of fact, that these imag
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
pson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorvee, 616 F.3d 174, 180 (2d Cir. 2010) ("We do not believe that the district court was clearly erroneous in finding, as a matter of fact, that these imag
bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec
106 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) 39 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 50 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 156 United States v. Dumitru, 18 Cr. 243 (LAK), 2018 WL 3407703 (S.D.N.Y. June 26, 2018) 170 United States v. Eldr
t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n
mpson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorvee, 616 F.3d 174, 180 (2d Cir. 2010) ("We do not believe that the district court was clearly erroneous in finding, as a matter of fact, that these ima
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
pson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorvee, 616 F.3d 174, 180 (2d Cir. 2010) ("We do not believe that the district court was clearly erroneous in finding, as a matter of fact, that these imag
Entities connected to both Schiller and Dorvee

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONJane Doe
PERSONColleen McMahon
PERSONMartindell
PERSONLoretta A. Preska
PERSON
Stephen Hawking
PERSONthe Southern District
LOCATIONSweet
PERSONJeffrey Pagliuca
PERSON
Prince Andrew
PERSON
United States
LOCATIONMartin Weinberg
PERSON
Virginia Giuffre
PERSON
Michael Jackson
PERSON
Eric Schmidt
PERSON
Southern District of New York
ORGANIZATION